Main v. Ozark Health, Inc., No. 19-1393 (8th Cir. 2020)
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The Eighth Circuit affirmed the district court's grant of summary judgment to Ozark in an action brought by plaintiff under the Age Discrimination in Employment Act of 1967 (ADEA), Title VII of the Civil Rights Act of 1964 (Title VII), and the Arkansas Civil Rights Act of 1993 (ACRA).
The court assumed without deciding that plaintiff satisfied her burden at step one of the McDonnell Douglas framework in establishing a prima facie case of age and sex discrimination, and held that Ozark articulated a legitimate nondiscriminatory reason for plaintiff's termination. In this case, Ozark satisfied its burden by presenting evidence that the decisionmaker terminated plaintiff because of her "rudeness and insubordination which culminated in a meeting in which she behaved abominably." Finally, plaintiff failed to demonstrate a genuine issue of material fact exists regarding pretext. The court also held that the fact that plaintiff's successor is male and twenty-two years younger than her cannot, by itself, create an inference that plaintiff was terminated based on her sex and age.
Court Description: [Shepherd, Author, with Colloton and Erickson, Circuit Judges] Civil case - Employment discrimination. Assuming plaintiff established a prima facie case of age and sex discrimination, Ozark established legitimate, non-discriminatory reasons for its decision to terminate her, which plaintiff failed to show were pretexts for discrimination; fact that her replacement was a male and younger could not, by itself, create an inference that she was terminated based on her age and sex.
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